Power to decide ownership, interpret contracts in ejectment cases

A defendant may not divest the MeTC of its jurisdiction by merely claiming ownership of the property.[1] Under Section 16, Rule 70 of the Rules of Court, "[w]hen the defendant raises the defense of ownership in his pleadings and the question of possession cannot be resolved without deciding the issue of ownership, the issue of ownership shall be resolved only to determine the issue of possession." Section 18, Rule 70 of the Rules of Court, however, states that "[t]he judgment x x x shall be conclusive with respect to the possession only and shall in no wise bind the title or affect the ownership of the land or building."The authority granted to the MeTC to preliminarily resolve the issue of ownership to determine the issue of possession ultimately allows it to interpret and enforce the contract or agreement between the plaintiff and the defendant. To deny the MeTC jurisdiction over a complaint merely because the issue of possession requires the interpretation of a contract will effectively rule out unlawful detainer as a remedy. As stated, in an action for unlawful detainer, the defendant’s right to possess the property may be by virtue of a contract, express or implied; corollary to this, the termination of the defendant’s right to possess would be governed by the terms of the same contract. Interpretation of the contract between the plaintiff and the defendant is inevitable because it is the contract that initially granted the defendant the right to possess the property; it is this same contract that the plaintiff subsequently claims was violated or extinguished, terminating the defendant’s right to possess. It was ruled in Sps. Refugia v. CA[2] that –
[W]here the resolution of the issue of possession hinges on a determination of the validity and interpretation of the document of title or any other contract on which the claim of possession is premised, the inferior court may likewise pass upon these issues.

[1] Consignado v. Court of Appeals, G.R. No. 87148, March 18, 1992, 207 SCRA 297, 305-306, citing De la Cruz v. Court of Appeals, G.R. No. L-57454, November 29, 1984, 133 SCRA 520, 528; and Ching v. Hon. Antonio Q. Malaya, etc., et al., G.R. No. 56449, August 31, 1987, 153 SCRA 412.

[2] 327 Phil. 982, 1006 (1996).